Fu-cheng Chen, V. Fukuen Eric Chen And Ming-fen Chen

CourtCourt of Appeals of Washington
DecidedAugust 19, 2024
Docket85333-3
StatusUnpublished

This text of Fu-cheng Chen, V. Fukuen Eric Chen And Ming-fen Chen (Fu-cheng Chen, V. Fukuen Eric Chen And Ming-fen Chen) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fu-cheng Chen, V. Fukuen Eric Chen And Ming-fen Chen, (Wash. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

FU-CHENG CHEN , No. 85333-3-I Appellant, DIVISION ONE v. UNPUBLISHED OPINION FUKUEN ERIC CHEN and MING-FEN CHEN, and their marital community; JASON TIE-JAY CHEN, a single person, and FKC LAND, LLC, a Washington limited liability company,

Respondents.

CHUNG, J. — Fu-Cheng Chen sued Eric Chen, one of his two brothers, to

enforce a contract that all three brothers signed regarding the distribution of

family property. The trial court dismissed with prejudice Fu-Cheng’s breach of

contract claim for failure to name a necessary party, his third brother. After a

bench trial, the court dismissed Fu-Cheng’s claim for a resulting trust arising from

a quitclaim deed he executed in 1995 transferring property in Illinois to his

nephew. Because the court erred by failing to determine whether joinder was

feasible, as CR 19 requires, we reverse the court’s dismissal of the breach of

contract claim with prejudice. We also reverse the court’s order awarding fees to

Eric as the party prevailing on the breach of contract claim. We affirm the court’s

dismissal of the resulting trust claim and remand for further proceedings

consistent with this opinion. No. 85333-3-I/2

FACTS

Fu-Cheng is the oldest of three Chen brothers. Fu-Cheng and the middle

brother, Eric, both moved to the United States, while the youngest, Kuan-Ming,

lives in Taiwan.

From 1970 until 2011, the Chens’ father bought real estate for them, a

total of 98 separate properties in Taiwan and the United States. While their

father’s name did not appear on the titles, he was in control and made all the

decisions about what properties to buy and sell. He titled these properties in his

sons’ names, and he alone decided whose name to put on which titles and in

what proportion. Most of the properties are titled in the name of one son only, but

more than a dozen U.S. properties are titled in both Fu-Cheng and Eric’s names,

and one U.S. property is titled in the names of all three brothers. Most of the U.S.

properties are located in Washington State, with others in Illinois, Indiana,

Arkansas, Texas, and California.

In 1988, the father bought 336 acres of farmland in Illinois from the Blum

family, the “Blum Farm,” for $2.4 million. The seller’s warranty deed conveyed a

60 percent interest in the property to Eric and 40 percent to Fu-Cheng. At that

time, Fu-Cheng lived in Taiwan and was not a U.S. citizen. In 1995, Eric learned

an Illinois law might impose a substantial penalty on agricultural property owned

by a non-U.S. citizen for more than six years. Eric told their father and Fu-Cheng

that there were two choices: place the property in a trust or title the property in

the name of Eric’s son, Jason, who was a U.S. citizen. Because Eric thought it

was not clear whether a trust would be safe, Fu-Cheng decided on the other

2 No. 85333-3-I/3

option, and executed a quitclaim deed conveying “all” his interest in Blum Farm

to Jason, who was seven years old at the time.

After Fu-Cheng deeded his interest in Blum Farm to Jason in 1995, the

Chens’ father acquired five Washington properties and titled all five solely in Fu-

Cheng’s name. In 2001, Blum Farm sold for more than $16 million. The proceeds

were used as part of a 1031 exchange; 1 Eric created FKC Land, LLC, with

himself and Jason as its members, and the company acquired 11 properties in

Washington State with the proceeds from the sale of Blum Farm. Two of the 11

properties FKC Land acquired were sold to it by Fu-Cheng. Eric took a $1.5

million distribution from the sale proceeds. Also, after the sale of Blum Farm in

2001, Fu-Cheng’s father acquired seven properties in Taiwan and titled them

solely in Fu-Cheng’s name.

The brothers’ father suffered a stroke in 2010. As he recovered, he

directed his sons to memorialize his wishes that the properties he acquired and

titled in their names should be “re-register[ed]” with 30 percent for Fu-Cheng, 40

percent to Eric, and 30 percent to Kuan-Ming. The brothers did so by signing the

Family Asset Distribution Agreement (FADA) in 2011. The next week, the

brothers and Jason, signed a memorandum (2011 Memorandum) that clarified

which properties were in the scope of the FADA and which were not. The 2011

Memorandum also clarified that the ownership of U.S. property in the scope of

the FADA is 30 percent for each brother and 10 percent for Jason. Finally, in

1 See 26 U.S.C. § 1031 (allowing postponement of payment of tax on gain upon sale of

property if proceeds from sale are reinvested in a similar property as part of a like-kind exchange).

3 No. 85333-3-I/4

2013, Fu-Cheng and Eric, their wives, and Jason signed an agreement (2013

Agreement) to form a U.S. company to hold the Chen family’s properties in the

U.S. and distribute shares in that company in a “3:3:3:1” ratio. Unlike the FADA

and 2011 Memorandum, Kuan-Ming did not sign the 2013 Agreement.

The brothers’ father recovered from his stroke but passed away in 2016.

The next year, the brothers began arguing about implementing the FADA. In

November 2020, Fu-Cheng sued Eric, Eric’s wife, and Jason, for a 40 percent

interest in Eric and Jason’s company, FKC Land, LLC. Fu-Cheng alleged several

claims, including that the intent of the parties was to entrust Eric and Jason with

assets for Fu-Cheng’s benefit, and Fu-Cheng was entitled to an equitable

resulting trust. In January 2021, Fu-Cheng amended his complaint and reduced

his claim to 30 percent of the land company. Eric answered for all defendants in

March, and in May he moved to dismiss for failure to join an indispensable party,

his brother Kuan-Ming. The court denied Eric’s 2 motion but ordered that Fu-

Cheng “shall file a motion to file an amended complaint as discussed on the

record no later than July 9, 2021.”

In July 2021, Fu-Cheng moved to amend. His second amended complaint

joined FKC Land, but not Kuan-Ming. It asserted claims for breach of contract

and specific performance, declaratory judgment, and other claims in addition to a

resulting trust.

In September 2022, Eric moved to dismiss with prejudice because Fu-

Cheng’s attorneys withdrew and he failed to comply with the court’s scheduling

2 Hereinafter, “Eric” refers to all the defendants collectively.

4 No. 85333-3-I/5

order. New attorneys for Fu-Cheng entered a limited appearance in October

2022 and argued for a continuance, which the court granted until January 2023.

On the first day of trial in January 2023, Fu-Cheng moved to voluntarily

dismiss the bulk of his claims, leaving for trial the contract claim and the resulting

trust claim, and the court granted the motion. 3 Fu-Cheng claimed that if the

FADA was enforceable, he was due both specific performance and damages

from its breach, and if it was not enforceable, that a resulting trust arose when he

quitclaimed his interest in Blum Farm to Jason.

In February 2023, after Fu-Cheng rested his case-in-chief, Eric moved for

judgment as a matter of law on both claims. The court found that Fu-Cheng

conceded specific performance “was impossible without Kuan-Ming being a

party.” It concluded that Kuan-Ming was a necessary party and dismissal of Fu-

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